Objective Evidence Of Nonobviousness Must Be Commensurate In Scope With Claims

In MeadWestVaco Corp. v. Rexam Beauty & Closures, Inc., Nos. 12-1518, -1527 (Fed. Cir. Sept. 26, 2013), the Federal Circuit affirmed-in-part, reversed-in-part, and remanded the district court's decision regarding validity and infringement of patents related to dispenser assemblies for perfumes.  Specifically, the Court affirmed the district court's claim constructions, denial of a motion to exclude expert testimony, denial of a motion for SJ of indefiniteness, and finding of infringement, but reversed and remanded the district court's SJ of nonobviousness.

Plaintiffs MeadWestVaco Corporation and MeadWestVaco Calmar, Inc. (collectively "MWV") and Defendants Rexam Beauty and Closures, Inc. and Rexam Dispensing Systems S.A.S. (collectively "Rexam") and Valois of America, Inc. and Valois S.A.S. (collectively "Valois") compete in the perfume packaging industry.  U.S. Patent Nos. 7,718,132 ("the '132 patent") and 7,722,819 ("the '819 patent"), assigned to MWV, are